Case Summary (G.R. No. 85934)
Background
SSK Parts Corporation is the petitioner in three consolidated cases originating from labor complaints filed against it. The complaints included claims by Teodorico Camas for illegal salary deductions, and further claims made by a union representing its members regarding underpayment of wages, non-payment of legal holiday pay, and service incentive leave. The Regional Director of the Department of Labor and Employment issued an order on January 11, 1988, in which the petitioner was directed to refund Camas for the illegal deductions and to settle unpaid wages and benefits owed to other employees within ten days.
Jurisdiction of the Regional Director
The petitioner challenged the jurisdiction of the Regional Director over the employee claims, asserting it lacked authority. However, according to Article 128-B of the Labor Code, as amended by Executive Order No. 111, the Regional Director has jurisdiction to enforce compliance with labor standards in cases where an employer-employee relationship exists. This jurisdiction extends to claims for wages and benefits not exceeding P5,000, pursuant to Article 129 of the Labor Code, allowing the Regional Director to decide on such complaints through summary proceedings.
Retroactive Effect of Amendments
The decision also references Republic Act No. 6715, which revised the provisions regarding the recovery of wages and other benefits. It may be applied retroactively in cases where vested rights are not impinged upon, as affirmed in previous case law. The examination of these claims by the Regional Director was valid under the provisions of the amended Labor Code, further supporting his jurisdiction in this matter.
Grounds for Contesting Jurisdiction
The petitioner argued that the Regional Director should not have jurisdiction since it contested the findings of labor violations. For such a jurisdictional challenge, three elements must be satisfied: (1) the employer must contest the labor officer's findings; (2) resolution of those issues must require analyzing evidentiary matters; and (3) those matters cannot be verified in the course of regular inspections. In this case, while the petitioner did contest the findings, the issues raised could be resolved based on evidence verifiable in an ordinary inspection, negating the need to refer the case to the National Labor Relations Commission (NLRC).
Claim of Denial of Due Process
The petitioner further contended that it was denied due process. The Supreme Cou
...continue readingCase Syllabus (G.R. No. 85934)
Case Overview
- The case involves a petition for review on certiorari by SSK Parts Corporation against Teodorico Camas and the Secretary of Labor & Employment.
- The decision was rendered on January 30, 1990, by the First Division of the Supreme Court of the Philippines.
- The case is consolidated under G.R. Nos. 85934, 85935, and 85936, concerning claims of illegal deductions, underpayment of wages, and non-payment of various employee benefits.
Background of the Case
- The complaints were initiated against the petitioner by Teodorico Camas for illegal deductions from his salary and by a union on behalf of its members for underpayment of wages, holiday pay, and other benefits.
- A routine inspection by labor regulation officers revealed several violations of labor standards by the petitioner.
- The Regional Director issued an Order on January 11, 1988, ordering the petitioner to refund illegal deductions and pay various unpaid wages and benefits to employees.
Findings of the Regional Director
- The Regional Director found that:
- SSK Parts Corporation illegally deducted P775.00 from Camas’s salary.
- Employees were owed overtime pay, legal holiday pay, service incentive leave, and living allowances.
- The Order mandated payment within ten days, with a warning of execution for non-compliance.
Petitioner's Claims
- The petitioner contested the Regional Director's jurisdiction over the c